G.R. No. L-64037 August 27, 1987
PROVINCIAL GOVERNMENT OF SORSOGON, petitioner, vs. ROSA E. VDA. DE VILLAROYA, et. al., GODOFREDO VILLAROYA, et al., AURORA VILLAROYA, et. al., and NICOLAS GALING, Presiding Judge of the Court of First Instance, Branches II & III, of the Province of Sorsogon (Now the Regional Trial Court No. 54 and 52, respectively), respondents.

FACTS

The case involves the execution of a final judgment in Civil Case No. 50 for recovery of real property. The then Court of First Instance of Sorsogon declared the private respondents as owners of a 16,500-square-meter lot occupied by Gubat High School. The dispositive portion ordered the Provincial Government of Sorsogon to pay P49,500.00 as the land’s value within one year from receipt of the decision, with the alternative obligation to vacate and deliver the land should it fail to pay. The decision became final and executory.
The petitioner province manifested its willingness to pay and appropriated the amount. However, the Commission on Audit (COA) imposed several documentary requirements on the private respondents before payment could be released. The respondents complied, but the COA later imposed an additional requirement for them to have the corresponding title issued in the name of the municipality, free from liens, as a precondition for payment. This caused further protracted delay, leading to the issuance of unsatisfied writs of execution.

ISSUE

Whether the COA can lawfully impose additional requirements, particularly the issuance of a clean title in the municipality’s name, as a condition for the payment decreed in a final and executory judgment.

RULING

The Supreme Court ruled in the negative and ordered immediate execution. The legal logic is anchored on the finality and immutability of judgments. The trial court’s 1974 decision explicitly outlined the obligations: the province must pay the sum, and upon such payment, the respondents must execute a conveyance. The judgment did not impose upon the respondents the duty to first procure and deliver a clean title as a condition precedent for payment.
The COA’s additional requirement was deemed unreasonable and a distortion of administrative rules, creating an unfair predicament for the private respondents who had already waited over thirty years for just compensation. The Court emphasized that when the government takes property for public use, it is the government’s duty to facilitate the payment process, not to hinder it with vexatious delays. The province’s obligation to pay is ministerial upon the finality of the judgment. Consequently, the Supreme Court set aside the lower court’s order enforcing the COA’s requirement, reinstated the original judgment, and directed the immediate payment of P49,500.00 with legal interest, authorizing the seizure of provincial assets if further delays occurred.